We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
We welcome this opportunity to comment on a review of the TV perimeter, and support ESMA’s objective of clarifying when systems and facilities qualify as multilateral.
EFAMA places huge importance on this revision of ESMA’s suitability guidelines, as they spell out in detail how investors can invest in sustainable investment products. If they are well designed, the guidelines have the potential to significantly boost capital flows towards sustainable investments; a goal that the European fund industry strongly supports.
The European Fund and Asset Management Association (EFAMA) welcomes the opportunity to respond to this important review of RTS 153/2013 and accompanying guidelines, in light of the procyclicality witnessed during the peak volatility of the Covid crisis. European CCPs already have standard anti-procyclicality tools in their rulebooks and this did lead to less volatile moves in margin in Europe versus other jurisdictions.
With the release of this proposal, the Commission is replicating the OECD / BEPS Inclusive Framework (OECD) Pillar Two Global Anti-Base Erosion (GloBE) Model Rules that came live in December 2021 and addresses how Member States will implement them in a coherent and consistent way across the EU. The work of the Commission and the alignment with the work of the OECD / BEPS Inclusive Framework are to be welcomed.
EFAMA fully supports the Commission’s initiatives to fight tax avoidance and aggressive tax planning. The work of the technical teams that acknowledged our industry’s special requirements and the proposal of carve-out rules to protect investment structures and end-investors are, to a certain extent, to be welcomed.
UCITS equity funds remained in high demand in January, contrary to bond funds
This is evidenced in the second edition of EFAMA's report, "The European Asset Management Industry's Engagement in Financial Education Initiatives", released in March 2022.
The report, prefaced by Commissioner Mairead McGuinness, is divided into three parts.
EFAMA appreciates the Commission's efforts in pursuing an alleviation of certain MiFID II requirements in the interest of promoting a swift recovery from the economic crisis precipitated by the Covid-19 pandemic (....).
EFAMA believes however that there are more effective ways to foster SME access to markets and urges the Commission to consider a set of further measures (...)
In light of the current COVID-19 circumstances and the already existing ambitious time table for the implementation, EFAMA calls for the EBA to carefully consider these circumstances and request the EC to postpone the date for the application of the IFD/IFR framework (26 June 2021) and the time table of the level 2 measures (such as the deadline of 26 December 2020 for providing drafted RTS and ITS).
EFAMA considers the Sustainable Finance Disclosure Regulation (SFDR) and its accompanying technical standards essential pieces in a strong and ambitious framework for sustainable investing. Its feedback aims at improving the effectiveness and feasibility of the ESAs’ proposal, as well as strengthening this regulation’s synergies with existing and upcoming rules.
A holistic approach is recommended when establishing whether the use of leverage of AIFs poses leverage-related systemic risk and materially contributes to financial instability. Any regulatory policies on leverage need to be evidence-based and developed with empirical evidence showing the extent to which the use of leverage in AIFs contributes to the build-up of systemic risk. The Covid-19 pandemic is testament that no major dysfunction was reported in terms of use of leverage by AIFs.
As highlighted in President’s von der Leyen guidelines for the new Commission, the complexity and sophistication of the Union’s financial system has opened the door to new risks of money laundering and terrorist financing. The European Union needs to step up its regulatory framework and preventive architecture to ensure that no loopholes or weak links in the internal market allow criminals to use the EU to launder the proceeds of their illicit activities.
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Our members enjoy significant benefits including the opportunity to shape the industry positions, get first-hand access to regulatory and political intelligence, engage with industry peers and policymakers, and take part in EFAMA events.
Our three membership categories cater to the wide range of organisations that make up and support the investment management industry in Europe.